Regulatory Sustentation 36: Labelling

As per our damnation post, while the the subject of labelling sounds harmless enough, it can still pose a nightmare for your supply chain. Products that are not properly labelled can be held up or seized at the border, seized for violation of state or federal labelling regulations from your warehouses or shelves, or result in massive fines and trade embargoes until the problem is corrected.

And it’s not as easy to adhere to labelling requirements as one might think. For example, in food and beverage, many jurisdictions require not only that all products contain nutritional information but also indicate whether or not the products are derived from GMO (Genetically Modified Organisms). In the tobacco industry, despite continuous threats of lawsuits from the tobacco companies, countries are starting to impose plain packaging laws and third parties dictate what packaging can and can not contain. In electronics, some countries are considering imposing laws that force a company to indicate the expected lifespan of the product being produced and how long it will be supported (as this is very important to a consumer spending hundreds, or thousands, on a new electronic device with the belief that the manufacturer is going to support the hardware and software for at least a few years). And different countries require different units, warnings, languages, etc.

This is not necessarily a bad thing, because consumers deserve to know what they are buying, but if multiple jurisdictions require different labelling requirements, it can be difficult to produce a label that satisfies all of the jurisdictions that operate under the same language. And if the company needs to produce a multi-lingual label that satisfies multiple jurisdictions in multiple countries, it can be a nightmare.

As per our damnation post, there are steps a company can take, namely:

  • the implementation of a Global Trade Management (GTM) solution,
  • careful review of each proposed label for full compliance before it is seen to the packaging supplier, and
  • monitoring for changes in labelling requirements so that the company does not get caught off-guard

but if a company is really ahead of the game, it will also:

    • monitor for proposed changes in labelling requirements and make sure it is in compliance before they happen if approval is likely and
    • monitor for key issues and complaints by buyers and find ways to proactively address issues before lawmakers tackle them and take a leadership position, which will improve the brand.

And, of course, make your labels as easy to understand as possible. If the product is packaged in 1L, don’t put nutrition counts for 278 ml against suggested daily values that aren’t even indicated on the package. NO one can quickly do that math in their head!

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